Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Penalty proceedings u/s 271(1)(c) - Failure of the assessee to explain the source of cash deposit in the bank account - burden of proof - The ITAT acknowledged the difference in the burden of proof between penalty proceedings and assessment proceedings. Mere disallowance or addition in quantum proceedings does not automatically warrant penalty imposition under Section 271(1)(c) of the Act. - Considering the mitigating circumstances, including the deceased status of the appellant and the difficulty in independently proving circumstantial facts, the tribunal concluded that the penalty imposition was not justified and directed its reversal and deletion.
Penalty proceedings u/s 271(1)(c) - Failure of the assessee to explain the source of cash deposit in the bank account - burden of proof - The ITAT acknowledged the difference in the burden of proof between penalty proceedings and assessment proceedings. Mere disallowance or addition in quantum proceedings does not automatically warrant penalty imposition under Section 271(1)(c) of the Act. - Considering the mitigating circumstances, including the deceased status of the appellant and the difficulty in independently proving circumstantial facts, the tribunal concluded that the penalty imposition was not justified and directed its reversal and deletion.
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